Update - Italy Publishes Instructions on Optional Exit Tax Deferral when Migrating to an EU or EEA Member State

On 10 July 2014, the Italian tax authorities (ITA) published Protocol No. 2014/92134, which provides instructions on Italy's recently introduced rules on exit tax options when migrating to an EU or EEA Member State.

Under those rules an Italian resident company or permanent establishment has three options when migrating:

• Immediate exit taxation of the deemed capital gains from the assets transferred
• Deferral of the exit tax on the capital gains until actually realized
• Pay the exit tax in 6 …